These three elements are also known as the CLASSIC TRINITY, as reaffirmed by the House of Lords in Reckitt & Colman Ltd v. Borden Inc. It was stated in this case that in a suit for deception, the plaintiff must establish the following: • Goodwill or reputation has been attached to goods or services over a particular period of time. • Misrepresentation by the defendant to the public (leading or likely to lead the public) to believe that the goods and services offered by him are those of the plaintiff. • A sufficient showing must be made that the plaintiff has suffered a loss as a result of the defendant's belief that the goods and services are those of the plaintiff. (May be actual loss or future loss) In the current scenario, the characteristics have been further studied and in the judgment in the case of Erven Warnink BV v. J. Townend & Sons (Hull) Ltd., 1980 RPC 31, Lord Diplock gave the essential modern characteristics of a substitution action. These are the following elements: • False declaration, • Made by a person in the context of commercial operations, • To the person's potential customers or to final consumers of goods or services supplied by